General disclosures

Alpiq's values foundation is part of the corporate culture and should at all times form the basis for all decisions and activities with stakeholders such as employees, business partners, investors, financial service providers and the public at all times.

To this end, the Alpiq Code of Conduct issued by the Board of Directors supports the corporate culture as a binding guideline for ethical behaviour with integrity and in compliance with the law. They are part of the employment contract and apply to all Alpiq Holding Ltd. employees, including managers, and the directly or indirectly controlled Group Companies in Switzerland and abroad. They are available in nine languages. All new employees are invited to internal training on the contents of the Code of Conduct when they start work.

Integrity requirements and compliance with the law are important when selecting our business partners. In order to ensure compliance with minimum standards here as well, a code of conduct for suppliers was drawn up in the reporting year. It is an integral contractual component for future supplier relationships.

Values, ethics and integrity are the foundation of Alpiq’s corporate culture and thus an important part of the comprehensive compliance programme when it comes to complying with laws and internal rules in order to avoid legal and reputational risks.

Alpiq maintains its Compliance Management System (hereinafter ‘CMS’) based on the traditional pillars of prevention, risk identification and response. Alpiq is guided by various recommendations such as the OECD Guidelines for Responsible Business Conduct, the Swiss Code of Best Practice and the UN Guiding Principles on Business and Human Rights.

Compliance management is an integral component of the comprehensive internal company risk analysis and assessment, which is carried out annually. Relevant fields of action for the compliance programme for the following year are derived from this, and necessary measures to be introduced are defined and/or adjusted. Alpiq’s compliance programme includes, among other things, the following fields of action: anti-corruption, fair competition, prevention of money laundering, counterparty audits, data protection, avoidance of conflicts of interest, and protection of people and the environment.

The Alpiq Board of Directors and the Executive Board are jointly and regularly committed to strong compliance (‘tone at the top’) and therefore emphasize its importance to the sustainable success of the Alpiq Group.

In addition, all managers are responsible for implementation of the Code of Conduct in the Alpiq Group Companies and always set a good example (‘tone at the middle’). The Code of Conduct is supplemented by topic-specific internal regulations.

Employee training sessions on various compliance fields of action are, along with the internal regulations, a key part of the implementation and assurance of the Alpiq CMS. Training content generally covers the defined fields of action and is appropriate for the target group. An electronic learning platform greatly supports and facilitates the execution and monitoring of training sessions.

Alpiq also applies its holistic compliance management approach when dealing with customers and business partners. The internal company process ‘Know your customer’ describes a part of the due diligence that serves to identify and screen Alpiq customers and business partners. Screening is carried out according to an individual risk-based model taking into account sanctions, embargoes, negative news, identification of politically exposed persons and the perception of corruption in certain countries or industries, etc. Using the database of a leading provider, Alpiq can assess the reputational risk associated with a counterparty or identify potential conflicts of interest. Information on convictions, economic beneficiaries or entanglements with other companies, among other things, are available. Audited counterparties are monitored by the system for material changes.

Alpiq conducts a personal security check on potential employees when recruiting for risk-sensitive or leading positions. The check is repeated every five years for the employees in question. The personal security check is particularly intended to protect Alpiq from fraud, corruption, money laundering or misappropriation of assets. As part of the audit, Alpiq obtains relevant official documents. Alpiq takes local laws and customs into account here.

In the reporting year, Alpiq commissioned an accredited auditing firm to conduct an independent maturity measurement to assess the Alpiq compliance programme. The result shows that Alpiq can rely on a solid and functioning CMS. Suggestions for improvement from this maturity measurement will be incorporated into the continuous improvement and further development of the CMS.

Employees at all levels can seek advice on specific compliance topics at any time. The internal team of compliance experts and local compliance partners in the respective countries in which Alpiq has employees are available for this purpose.

Alpiq has a great interest in immediate notification if compliance with ethical and lawful conduct in its area of responsibility is not ensured. The compliance reporting office is an essential element for identifying and clarifying misconduct and addressing weaknesses. Alpiq provides various reporting channels for this purpose. In addition to a telephone number and email address set up specifically for this purpose, the compliance reporting office can also be contacted via an online form. The contact details are published in the Alpiq Code of Conduct, on the Alpiq Intranet and on the official Alpiq website. The compliance reporting office is mainly aimed at employees, but is generally open to everyone. Alpiq also welcomes reports from former employees, service providers, customers or third parties.

The online form enables the whistleblower to send a message without disclosing their identity. This online form is available in nine languages. Data entry and processing take place entirely outside the Alpiq IT infrastructure. This ensures that tracing is impossible. Anonymous reports are examined just as carefully as those that are not submitted anonymously. Alpiq ensures that employees who submit a report in good faith do not suffer any disadvantages as a result.

Alpiq is guided by the requirements of the ‘EU DIRECTIVE (EU) 2019/1937 on the protection of persons who report breaches of European Union law’. Alpiq has created the same conditions for all Alpiq Group employees – and also third parties – when it comes to reporting concerns, regardless of whether or not the EU Directive applies in that country. The compliance department confirms receipt of the report within seven days and gives the whistleblower feedback within a maximum of three months. The whistleblower will be informed of the consequences of their report after the investigation has been completed unless personal rights of data subjects or company interests oppose this action.

Suspected cases are investigated by the compliance experts and/or local compliance partners. Where the scope and/or complexity of an investigation exceeds the capacity of the compliance department, the investigation may be delegated to the internal audit department or a specialised external service provider. Infringements are corrected or punished based on the options afforded under labour or contractual law as applicable.

The governance structure of Alpiq Holding Ltd. (including the committees of the Board of Directors as the highest governance body) and the committees responsible for decision-making with respect to economic, ecological and social topics can be found in the Corporate Governance section of the Alpiq Holding Ltd. Annual Report 2021.